NOORo III Tower CSP Plant, Ouarzazate, Morocco. Non-Technical Summary. ACWA Power. March Public Disclosure Authorized

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1 Public Disclosure Authorized Public Disclosure Authorized Public Disclosure Authorized Public Disclosure Authorized NOORo III Tower CSP Plant, Ouarzazate, Morocco Non-Technical Summary ACWA Power March Capitals Environmental and Management Consulting PO Box , Sheikh Zayed Road, Dubai, UAE Tel: Fax:

2 Document Information Project Project Number 1305/001/010 Report Title Client Project Manager Project Director Non-Technical Summary ACWA Power Zeina Jokadar Ken Wade Document Control Rev Issue Date Description Author Reviewed Approved 1 06/09/2014 For pre-bid submission ZMJ CPM KRW 2 19/12/2014 Review following IFI s comments ZMJ CPM 3 31/12/2014 Review following IFI s comments ZMJ CPM 4 27/03/2015 Final ZMJ CPM CPM KRW NOORo III TSP Non-Technical Summary Final i

3 List of Abbreviations Abbreviation ACWA Power AP BAT BOO CESMP CEMS CNEIE CSP db(a) EHS ESMP EMS EPC EPFI FESIA ha hm 3 IFC MASEN MEMEE NOx NO2 OESMP O&M PAH PM10 / PM 2.5 PPE SESIA SPC SO2 SPC CSP TSS Meaning Arabian Company for Water and Power ActionPlan Best Available Techniques Build, Own and Operate Construction Environmental and Social Management Plan Continuous Emission Monitoring System Committee National de EIE Concentrated Solar Power A-weighted decibels Environmental, Health and Safety Environmental Management Plan Environmental Management System Engineering, Procurement and Construction Equator Principle Financial Institutions Framework Environmental and Social Assessment Hectares Cubic Hectometres International Finance Corporation Moroccan Agency for Solar Energy Moroccan Ministry of Energy, Mines, Water and Environment Nitrogen Oxide Nitrogen Dioxide Operational Environmental Management Plan Operation and Maintenance Polycyclic Aromatic Hydrocarbons Particulate matter with an aerodynamic diameter of less than 10 / 2.5 micrometers. Personal Protective Equipment Specific Environmental and Social Assessment Solar Power Complex Sulphur Dioxide Solar Power Complex Concentrated Solar Power Thermal Storage System NOORo III TSP Non-Technical Summary Final ii

4 Abbreviation Meaning VOC Volatile Organic Compounds WWTP Wastewater Treatment Plant 5 Capitals 5 Capitals Environment and Management Consultancy NOORo III TSP Non-Technical Summary Final iii

5 REPORT STRUCTURE In order to comply with the requirements for environmental assessment and international best practice, this report is presented in the following format: Volume 1: Non-Technical Summary and Main Text Volume 2: Technical Appendices Volume 3: Environmental and Social Management Plan Volume 1 comprises the Non-Technical Summary and main text of the report with the issues identified that the NOORo 2 CSP may impact upon (following the framework assessment) each following a similar general structure: Introduction and Project Background; Legal Framework, Standards and Guidelines; Methodology; Baseline Information; SESIA Assessment Method; Assessment of Effects/s, Mitigation Measures, and Residual Effects During Construction Phase; Assessment of Effects/s, Mitigation Measures, and Residual Effects During Operational Phase; and Assessment of Effects/s, Mitigation Measures, and Residual Effects During De- Commissioning Phases, where relevant. Volume 2 comprises all Technical Appendices (consultation meeting, baseline survey reports, monitoring reports and other Technical Studies). Volume 3: provides the framework for the development of the Construction Environmental Social Management Plan (CESMP) by the main contractor and all sub-contractor; and the Operational Environmental and Social Management Plan (OESMP) to be developed by the project proponent and implemented by the Operation and Management (O&M) team. NON TECHNICAL SUMMARY The Moroccan Agency for Solar Energy (MASEN) is planning to construct a 500MW Solar Power Complex in Ouarzazate, to meet the national renewable energy policy objectives. The consortium, lead by ACWA Power has been awarded the EPC for the third phase of the Solar power Complex, which will produce 150MW using Tower Concentrated Solar Power (CSP) technology. Non-Technical Summary Final 1

6 MASEN prepared a Framework Environmental and Social Assessment (FESIA) for the 500MW Solar Power Complex. 5 Capitals Environmental and Management Consulting (5 Capitals) has been commissioned by ACWA Power to undertake the Specific Environmental and Social Assessment (SESIA) for the proposed NOORo III Tower CSP (NOORo III tower CSP Plant, the Project ), in Ouarzazate, Morocco.. A Specific Environmental and Social Assessment was prepared for NOORo 1 prior to the start of construction, and another SESIA is being prepared for NOORo 2. The project is situated in a greenfield of the Ghessat Ogrour Toundout rural commune area commonly known as "Tamzaghten Izerki" along the national highway connecting Ouarzazate and Errachidia. The proposed site is approximately 10Km north east of the city of Ouarzazate and 4Km north of National Road N10. The specific plot for NOORo III is located at the northern extent of the total SPC site, north of the NOORo 1 plant that is under construction and north of the plot for NOORo 2, which will be constructed at the same time as NOORo III. The site for NOORo III has a total area of 598ha. The electricity generated will be supplied to the Ouarzazate 225/60 KV station located near the complex. The proposed project site is located on a sparsely vegetated and flat rocky plateau, which is crossed north to south by Chaabas. Prior to construction of Phase 1 of the Solar Power Complex, the plateau was used by nomads for crossing and while crossing for cattle grazing, even though the grazing quality was low due to the sparse vegetation. It is understood that construction is expected to last approximately 30 months, from the Notice to Proceed, followed by 1 year of optimization and demonstrating performance guarantees to reach Final Commercial Operation. The SESIA has been prepared in accordance with Law No for the Protection and Improvement of the Environment and Law No for the Environmental Study Process of Morocco. Equally, the environmental and social requirements of the IFIs have been taken into consideration for the preparation of this SESIA. Under Moroccan and international guidelines for environmental impact assessments, the evaluation of various project design and activity alternatives were considered, in order to ensure that the objectives of the proposed project have accounted for social, ecological, economic and technological options. The following project alternatives were considered: No Project Non-Technical Summary Final 2

7 The No Project option is not a viable alternative, as the objective of the renewable energy law is to diversify the sources and production measures of power for the Kingdom of Morocco. Alternative solar power production technologies The Framework Environmental and Social Assessment (FESIA) that was carried out in January 2011, identified and assessed four technologies for solar power production in relation to ecological and social settings of the proposed site. The alternative technologies considered included: Photovoltaic without tracking devices, photovoltaic with tracking devices, solar power tower with solar farm, and parabolic trough solar field. The solar power tower with solar farm was identified as the preferred choice, as power could still be generated during lower solar irradiance without the use of boilers, and the power reserve in low solar irradiance periods is greater than with other solar farm technologies. Alternative project location and layout The location of the NOORo 2 CSP is restricted at the southern and northern boundaries by the under construction NOORo 1 and proposed future NOORo III tower CSP, respectively. Furthermore, the eastern boundary of the site abuts the newly built access road, and any possible shift to the west is prevented by the presence of the Chaabas and canyon. The environmental assessment has considered all environmental Issues relating to the commissioning, construction, and operation works associated with the Project, which include: Soil contamination Water and Wastewater Management Air quality Noise and vibration Solid and hazardous Materials, Stormwater management, Ecology and Biodiversity Traffic and transportation, Socio economic, Cultural heritage and archaeology, and Landscape and Visual. In response to the assessment of each of these environmental disciplines, a range of specific mitigation measures have been set out to prevent, reduce or remediate the potential impacts identified as a result of both construction and operational phases of the Project. Non-Technical Summary Final 3

8 It should be noted that the decommissioning phase of the project has only been discussed in general terms, since the NOORo III tower CSP Plant is contracted under a 25 year BOOT scheme (Build-Own-Operate-Transfer). Therefore, the ownership of the SCP will be handed over to MASEN at the end of the 25 year period and consequently the responsibilities for the decommissioning of the plant will fall under the responsibility of MASEN. However, mitigation measures to address significant issues during decommissioning (such as waste management, hazardous waste management, and prevention of associated secondary impacts such as soil contamination) are included in the SESIA and will be developed in more detail in the decommissioning plan to be drafted prior to the start of the decommissioning activities. The cumulative effects of all phases of the SCP and other any identified neighbouring commercial and industrial facilities have been included in the assessment of impacts, in addition to the potential residual impacts following the implementation of the recommended mitigation measures. Air quality and noise modelling was undertaken to assess the extent and pattern of dispersion of these pollutant/nuisances in relation to the closest sensitive receptors within and off the proposed project site. Soil Contamination Soil will be susceptible to contamination from various sources during the construction and operational phases of the project. The main sources of contamination are typically those places along the handling and processing of products where liquid waste and hazardous material can escape into the soil. These are commonly associated with the transport, handling and storage of such materials and the potential threat of releases and spills into the ground. These include, for example, fuel spills, industrial wastewater and sanitary wastewater spills, oils and lubricants leaks or washed-off by rainwater. Considering that the site is a greenfield and no commercial or industrial activities are located in close proximity to the site. Due to the previous land uses onsite (passage on foot and pastoral activities) there is no reason to believe that hydrocarbon contamination of soils could be problematic. No evidence of hydrocarbon spills was identified during the different site surveys. Soil sampling and analysis was carried out for heavy metals and the results indicate that the soils onsite are not contaminated. The data obtained will be used for comparative assessment purposes in the event of a spill or leak to verify that remediation was successfully completed and for cumulative assessment purposes over the lifetime operation of the plant. The results of the sampling campaign showed in general the level of heavy metals from the soils collected on site, were below the Dutch target values and Canadian Indicative Values. One sample collected offsite, from the ravine draining to the Oued on the western side of the site, recorded high levels of Barium. However, given the soils were predominantly clay Non-Technical Summary Final 4

9 and the sample was collected from a rain channel, the high levels are attributable to accumulated absorption in the soils, and not an indication of contamination. Therefore, based on the analytical information, historical land use and site observations, it can be concluded that the soils on site are not contaminated by heavy metals. Prevention, control and remediation of any spillages and leaks at the construction phase will be managed in accordance with the mitigation measures identified in the CESMP. These methods and practices are well established and proper training and implementation of the mitigation measures identified in the CESMP will ensure that risks are minimized and any negative impacts are insignificant. The mitigation measures include, but are not limited to, the storage of chemicals, fuels, lubricants and paints on dedicated locations such as paved ground surfaces to prevent leakage into the ground; the storage of hazardous liquid waste and chemicals, such as oils, etc. in contained areas where oil drums have drip collectors to avoid spillage to the ground; and spillage and leakage prevention measures including regular inspection of containers. Water and Wastewater Management The construction and operation of NOORo III tower CSP will result in water consumption and in the generation of a number of wastewater streams that will require appropriate management techniques to be employed to ensure compliance with international best practice. The main wastewater contamination risks arising during construction relate to sanitary waste and to contaminated wastewater generated by storm water events washing oil spills from construction vehicles machinery. The quantities of sanitary wastewater can be estimated at approximately 54,556 m3 for 30 months. This wastewater will be generated and stored on-site prior to removal by a licensed contractor. Mitigation measures are outlined to ensure that the handling of sanitary wastewater is done in such a way that pollution events are minimised. To avoid storm water runoff getting contaminated by oil spills, all vehicles onsite shall be adequately maintained and any repairs or maintenance will carried out over impermeable surfaces with the appropriate containment and runoff collection mechanisms. The proposed source of water for this project is the Mansour Ed Dahbi reservoir. Contributions to the Mansour Ed Dahbi dam average 420 hm 3 per year (varies from 68 to 1300 hm 3 ). The rate of filling of the dam has experienced fluctuations over the years ranging from 12% to 40% and over 90% in the last few years (97% on 04/05/2010). The provision reserved for drinking water from the Mansour Ed Dahbi dam is 3.5 to 4 hm 3 /year against approximately 180 hm 3 /year for irrigation. Evaporation losses are estimated at about 56 m 3 /year. In years of drought, the buffered groundwater driven system of the north-eastern regions provides a Non-Technical Summary Final 5

10 reliable base for irrigation and an almost constant inflow of 50 hm 3 per year to the reservoir. This assures that even in years of severe drought the reservoir does not dry up. The water use for NOORo III tower CSP will be 0.2 hm3 over 30 months (0.087 hm3/year) during construction and 0.2 hm3/year during operation. This represents 0.13% and 0.29% respectively of the lowest recorded contribution to the Mansour Ed Dahbi Reservoir, that is 68 hm3. Freshwater from the Mansour Ed Dahbi Reservoir will be treated onsite to the required quality parameters. The main wastewater sources during operation will be sludge from dissolved air floatation, cycle blow down, concentrate from reverse osmosis, boiler blow down, oily water, and sanitary water. These will be treated according to their characteristics, reused for lower quality uses when possible and otherwise discharged to evaporation ponds. The estimated total wastewater flow to be discharged to the evaporation ponds is 33.4m3/h. As a result of this, there will be no wastewater discharges from the plant during the operation phase. Air Quality The proposed NOORo III tower CSP Plant will be built in a relatively isolated area. The closest large town, Ouarzazate, is over 12Km from the site and only two roads, RN 10 and RP 1511, currently pass adjacent to the project. Long-term traffic on these roads is limited to light commercial and private transport, with few heavy vehicles being used for small construction projects, such as houses or small/low-rise buildings. Recently, heavy vehicle traffic has increased due to the construction of the NOORo 1 CSP, however, this is considered a short term impact, and the frequency of vehicle use will decrease as the quantities of major equipment and building materials decreases. No heavy industries are found as far as 75Km upwind from the site, this is due to the topography of the Atlas Mountains range. Equally, further north in the Province of Marrakesh, no heavily polluting industries are found. The main commercial activities in the area are agroindustries (processing of fruit and vegetables, wool, flour), building materials, leather goods production and carpet production. As a result, point source and non-point source emissions around the proposed project area are insignificant and any impacts to the ambient air quality are considered negligible. During construction, the ambient air quality at local receptor sites may potentially be affected by increased dust, particularly during the earthworks phase and by gaseous exhaust fumes from construction vehicles, plant and additional vehicle movements to and from the site. At the operational phase impacts to the air will be insignificant, and originating from the boiler when it is operated. Non-Technical Summary Final 6

11 Thanks to the remoteness of the site and absence of neighbouring heavy commercial and industrial developments the background air quality is considered good and well below the National and WHO limits for ambient air quality. Monitoring was however carried out in order to develop a benchmark for the site. The parameters monitored were SO2, NOx, VOC and PM10. These parameters were selected, as they are the typical emissions resulting from construction and operation of the proposed Solar Power Plant. The data obtained will be used for comparative and cumulative assessment purposes during the routine air quality monitoring programme, which is to be implemented at the construction and operational phases in accordance with the procedures established within the CESMP and OESMP. The results of the monitoring campaign show that the ambient air quality conditions within and adjacent to the NOORo III Solar Power Complex are well within the national ambient air quality guidelines for SO2, NOx, O3 and PM10. According to these parameters, the air quality on the site can be considered good. Green House Gas (GHG) Generally, solar power plants by their very nature are low emitters of air pollutants. The objective of the facility is to use renewable and clean fuel to generate power. The clean fuel in this type of operation is solar heat that is magnified by the mirrors, trapped by an oil which is then converted into thermal energy within a boiler to produce steam for a conventional steam turbine. In fact, the solar power plant will have a net positive impact on the regional air quality, as it will prevent approximately one million tonnes of CO2 per year from being emitted, if a conventional fossil fuel power plant had been used (according to the MEMEE estimates). Therefore, the solar plant is helping to offset negative impacts from CO2 emissions and the effects of Global Warming. The Project will have back up heating to maintain the heat/conversion system when solar heating isn t available, and to keep the salt for storing heat in a liquid state. As such air emissions from the boilers will meet the appropriate WBG EHS Guidelines for thermal power generation. As the boilers will be used primarily for standby heat, they are likely to run less than 500 hours per year, the threshold for the application of the WBG air emission guidelines. The Project will nonetheless monitor the hours of operation and the air emissions of the boiler. These boilers will be the primary source of green house gases (GHG) for the Project. Noise and Vibration The proposed site is located in an isolated area, with no significant developments or commercial activities located within a 6 Km radius. The only identified source of noise is sporadic in nature and emanates from the two roads, which run parallel to the site. In the Non-Technical Summary Final 7

12 past, traffic was light and consisted of private vehicles and light commercial trucks. However, recently construction activities for NOORo 1 CSP have started and as a result noise levels have increased, however this is considered uncharacteristic of the typical historical noise conditions and is temporary in nature. Noise impacts during construction will be generated by construction machinery and activities, and the main sensitive receptors will be workers and road users. Due to the impact of topography and distance on noise propagation, the village of Tasselmant is not likely to notice noise impacts. During operation, continuous noise sources will be located in the power island. Due to the impact of distance attenuation on noise propagation, noise levels at the project boundary are expected to be of little significance. The modelling suggests that this noise can amount to 50dB. Due to the continuous nature of the operations, it is anticipated that the noise impacts are likely to resemble humming noises, combined with sporadic noises from certain processes, mobile equipment and moving vehicles. The noise will not impact any residential dwellings and is unlikely to be noticed by road users. The proposed site is located in an isolated area, with no significant developments or commercial activities located within a 6 Km radius. The only identified source of noise is sporadic in nature and emanates from the two roads, which run parallel to the site. Consequently, the noise would be anticipated around 35-40dB, with sporadic levels reaching 60dB due to traffic. In order to develop a benchmark of the onsite noise conditions, a noise monitoring campaign was carried out in the day and night-time in February The data obtained will be used for comparative and cumulative assessment purposes during the routine noise monitoring programme, which is to be implemented at the construction and operational phases in accordance with the procedures established within the CESMP and OESMP. The results of the monitoring campaign show that both the day-time and night-time noise levels at the boundaries of the SPC, reflect a quiet, undeveloped area. The levels do not change significantly between night and day and they are below the maximum allowable noise limits for residential areas. The average noise levels along the road reflect typical noise levels that would be generated by light traffic. Additionally, there is no significant change between the night and day readings, and in comparison to the Industrial/Commercial limits, the levels are compliant. During the construction stage and in accordance with the typical Health and Safety requirements, no employee should be exposed to a noise level greater than 80 db (A) for duration of more than 8 hours per day without hearing protection. Hearing protection should Non-Technical Summary Final 8

13 be provided for all employees working in close proximity to equipment with noise levels >85 db(a). During operation, the EPC contractor will be required to comply with at least a 60 db(a) standard 1m from the SPC boundary fence line. Modelling has been undertaken and shows that at the site boundary the noise from the power island is reduced to less than 45dB(A). In addition the noise levels at sensitive receptor sites identified in the SESIA, due to the plant operation, will be required to meet WB/IFC standards for industrial and residential receptors respectively. This will be tested by the EPC during the commissioning phase of the project to demonstrate compliance. In order to achieve the relevant standards, mitigation measures and silencer performance specifications will be required and are described in the SESIA. A programme of on-going monitoring will be carried out at sensitive receptors to ensure compliance with World Bank/IFC noise standards. Solid and Hazardous Wastes During construction, waste would be generated during earthworks, construction of the fence, paths, road accesses and buildings, and connecting the power systems to the network. The main types of waste generated would be sand, gravel, concrete, asphalt, scrap steel, glass, plastic, wood, packaging materials and municipal waste from construction workers. Construction material is mainly inert and does not pose a threat to human health or the environment. However, proper management is required in order to reduce associated secondary impacts such as resource use, dust emissions, and habitat destruction. The hazardous fraction of construction waste will represent less than 15% of the total amount of construction waste likely to be generated, its disposal requires careful consideration During operation, solid wastes will be generated at several facilities within the power block. Some of these will be direct products resulting form the operation and maintenance of the facilities, whilst other wastes will be the by-products of primary waste treatment processes, for example the sludge that results from wastewater treatment. In addition to solid waste generation from the tower CSP, domestic waste from the administration and canteen facilities will also be generated. With regards to hazardous wastes, these will include: Sludge from the various waste water and waste oil treatment processes; Heavy metals within the sludge; Waste oil, oily sludge, oily rags, chemicals, solvents from general maintenance of onsite plant and machinery; Used chemical and fuel drums; Non-Technical Summary Final 9

14 Used filter mediums; Soil contaminated by potential spills and leaks; Miscellaneous wastes such as batteries, wire cables, and General clean-up materials. The mitigation measures proposed will help to reduce the impact significance for both construction and operation waste to minor and moderate levels. These mitigation measures refer to both hazardous and non-hazardous wastes, as there is much overlap in the treatment and handling mechanisms for both types of wastes. All elements of waste mitigation are captured in the Waste Management Plan of the CESMP, OESMP. The mitigation measures will be cross-referenced within the Waste Management Plan and focus predominantly on the appropriate handling, storage, segregation, transport, and disposal of all waste. Such mitigation measures include: Segregation and storage; Use high quality raw material; Reduction of packaging. Recycling; Regular inspections, audits, and monitoring of waste streams generated; Bunding of hazardous wastes and storage in protected areas. Collection and transport by licenced handlers. Implementation of spillage and leakage prevention measures; Mandatory training program for employees to increase awareness of waste management. These measures are identified as a means to ensure that resources are efficiently utilised and pollution is controlled. Stormwater Management The characteristic erosion patterns observed at the site are a result of the combined effects of the precipitation, topography, soils types and sparse vegetation cover in the study area. The generated surface run-off and ephemeral streams have resulted with siltation problems in the Mansour Ed Dahbi Reservoir. The project will change the patterns of storm water runoff and divert the Chaabas that run through the site. This can potentially lead to increased erosion and flooding risk downstream. The drainage system on site is designed in such a way that the rainfall that falls into the areas where there could be oil contamination would be collected, treated and discharged to the evaporation ponds. The rest of the rainwater falling on the site will be channelled through pipes and concrete ditches to the canyon to the south east of the site. Non-Technical Summary Final 10

15 An erosion protection design shall be implemented to protect against erosion at each discharge point. Re-vegetation will be undertaken on the canyons to further protect the area against erosion and reduce silt contributions to the Mansour Ed Dahbi Reservoir. Ecology and Biodiversity A detailed three-day ecology site survey was carried out in 2010 for the FESIA, covering the SPC site and nearby areas, to identify different habitat types and species present. Consequently, a follow up Rapid Ecological Assessment of the site was undertaken in May 2014 to verify if any significant changes to the ecological conditions had occurred. The site is located on a rocky plateau on the border of the South Atlas Mountains. Due to low rainfall in these areas, the vegetation is typically sparse and concentrated along the Oueds and drainage patterns that traverse the plateaus in a north to south direction. The biological diversity of the fauna and flora is therefore concentrated around these vegetated areas. Few endemic species and no threatened or endangered species were encountered during any of site visits, although the Spiny Tailed Lizard, which is listed as Near Threatened on the IUCN red list, has been historically recorded in these areas. Generally, the biological diversity of the site was considered low and would not be significantly impacted by the development of the proposed project. Five protected areas have been identified within a 15Km radius of the site. However, they are all located outside the potential impact zone of the proposed project, with the exception of the South Moroccan Oasis Biosphere Reserve and the Mansour Ed Dahbi reservoir Ramsar site and an Important Bird Area (IBA). The South Moroccan Oasis Biosphere Reserve includes the entire province of Ouarzazate, and the Mansour Ed Dahbi reservoir is located approximately 7.5 km south of the southern boundary of the site and could potentially be affected by the project. Regarding the South Moroccan Oasis Biosphere Reserve, the proposed project is located within Zone B of its framework management plan, which is defined as a buffer zone with the objective of only permitting developments that are compatible with conservation principles. Water abstraction from the Mansour Ed Dahbi reservoir has been minimised by using dry cooling and treating and reusing water, to minimise impacts on the wetland. Solar plants have a variety of potential impacts on avifauna, such as impact trauma or electrocution. However, there is a specific concern about solar tower facilities, the solar flux. Solar flux, or concentrated sunlight, is a measure of how much light energy is being radiated in a given area. The available evidence on avian mortality caused by tower CSP plants is contradictory. Laboratory tests suggest that damage to avifauna due to avian flux impacts is not a high risk. The monitoring data from a tower power plant in California (Ivanpah tower Non-Technical Summary Final 11

16 CSP Plant) shows avian mortality rates that are higher than those reported in the other plants using parabolic CSP or PV technologies (Genesis CSP Parabolic and Desert sunlight PV) where similar monitoring was undertaken. The reported mortality rates were approximately twice as high in the Tower CSP than in the PV plant and four times higher in the tower CSP than in the parabolic CSP. However, the reported impact on water birds was lower in the tower CSP plant, accounting for a 11% of the total fatalities, compared to 20% in the parabolic CSP plant and 48% in the PV plant. The impact on water birds of solar plants is caused by collisions, when water birds confuse the reflection of the continuous surface of mirrors or panels with the reflection from water. It seems that water birds are less likely to confuse the way that mirrors are arranged in tower CSP plants with water. The data from tower PPs in Spain and the Al Naqab Desert shows much lower mortality rates than in the Ivanpah plant. Even if the figure of the Ivanpah PP is considered to be more realistic, the avian mortality caused by tower CSP plants is low compared to other mortality rates caused by other human activities. Recommended mitigation measures include covering the evaporation ponds with a net to avoid aquatic birds accessing them, and not using large shrubs or trees onsite, as the existing evidence suggests that it attracts both birds and insects to the site. Daily monitoring will be undertaken to obtain a clear picture on the impacts of the solar tower technology in Ouarzazate. Based on the results of the monitoring, a mitigation plan for avifauna will be designed, potentially including measures such as model predators, gas cannons, pyrotechnics, bio-acoustic deterrents, falconry, and radio-controlled model aircraft to minimise avian fatalities. Socio Economics The report has considered the social and economic aspects associated with the development and subsequent operation of the NOORo III tower CSP. The assessment was informed through desk-based study and site visits. The proposed project is located within an uninhabited area of the Ait Oukrour Toundout ethnic group, and was used for grazing by pastoralists; therefore the project did not require the relocation of any communities. The land purchase by MASEN was completed in October/November 2010, and was conducted in accordance with statutory terms of sale. The review commission established the purchase price, and the funds were put into a special account on behalf of the Ait Oukrour Toundout Collectivity at the Ministry of the Interior, and will be managed by the Directorate of Rural Affairs. MASEN has also undertaken a socio-economic study and has prepared a socio-economic Action Plan, which will be used in conjunction with the CESMP and OESMP to ensure that the Non-Technical Summary Final 12

17 community s and employee s concerns and complaints are addressed through appropriate initiatives. Furthermore, the assessment confirmed that there will be a positive impact upon the local and regional economy as a result of the plant, due to employment, increased local spending on goods and services and increased training levels within the local community. The operation of the plant will provide electricity to communities further afield and will ensure a reliable source and increased power supply to the neighbouring communities; thereby facilitating the development and expansion of commercial and small industrial businesses. With regards to employment, the opportunities for women to gain work experience will be increased. A targeted system of local recruitment and investment in the human capital of the local workforce will enhance this process and consequently increase the benefit to the local economy. Up to 1,000 workers will be employed during construction and 60 during operation. Overall the various community consultations indicated that the local population perceived the project with a positive outlook for the creation of jobs and boosting the local economy. The cultural heritage and the natural landscape are important for the tourist industry at Ouarzazate. As it is explained in the landscape and in the cultural heritage sections, the impacts on the cultural and natural landscape are not expected to be significant, so from an economic perspective the potential negative impact on tourism is assessed as negligible. Additionally, MASEN will create a tourist site within the tower CSP, as one of the initiatives to boost commerce at the neighbouring villages. Further details of the socio-economic mitigation initiatives are provided in the Framework Environmental And Social Management Plan (ESMP), Volume 3. Traffic and Transportation Ouarzazate is linked to Marrakesh by the N9 and to Errachidia by the N10. There is no bypass road to Ouarzazate, so all traffic bringing equipment from the ports will cross the city. A noise baseline has been prepared for this sensitive receptor and is discussed in the noise section. As a result of the construction of the three solar projects, a paved road has been built by MASEN for direct access from the N10 to the village of Tasselmant. Transport of containers would be carried out mainly through the harbor of Casablanca. Then road transport would be carried out from Casablanca to Ouarzazate, crossing the Atlas, for most sensible supplies. For all sensible supplies like reflectors, HCE tubes, etc the alternative route Casablanca Agadir Ouarzazate would be used. Non-Technical Summary Final 13

18 One of the main port traffic volume expected is related to the Salt media (NOORo II & NOORo III), which is provided in big-bags. This transport would be carried out through the Casablanca port also. All the considered routes use the N9, cross Ouarzazate and get to the access road through the N10. Therefore, construction activities will lead to an increase in vehicle numbers and traffic on the N9, and N10. During the peak construction period an expected traffic around 40 trucks per day would pass through the town of Ouarzazate To reduce the impact derived from the transport of the construction workforce to the site on the N10 and on Ouarzazate, worker buses will be considered, as these will significantly reduce the number of vehicles accessing the site during construction. A car-pooling scheme should be implemented during operation. Wherever possible, heavy vehicle movements will be scheduled outside of peak periods and avoid times when nuisance will be higher. The construction vehicles leaving the site will be appropriately cleaned and all the vehicles used in the site shall be appropriately maintained. Therefore, bearing in mind Main container/truck traffic volume expected from Casablanca port and from Tanger (road transport from Europe), preliminary traffic estimation is as follows: - 40 trucks per day during peak construction activities - Experience during NOORo 1 construction has shown that the existing roads Casablanca Ouarzazate can handle with minimum impact additional traffic demanded by the construction of the Solar Plant. - For HGV transport the port to be used will be mainly Nador, although possibilities of using Agadir port would also be considered. Special transports are considered those exceeding 60 t, which will require a special authorization. The following special transports (near 60 t or bigger) are foreseen. Nador Ouarzazate road has not a high traffic demand, therefore it is not foreseen a high impact of the HGV transport on this road. Additionally these special transports would not cross the city of Ouarzazate. And impact on traffic of these special transports is not considered especially critical for the existing traffic if they are adequately & timely scheduled. Finally, since construction of the two plants will be in tandem the traffic will be managed in tandem. This will enable to avoid cumulative impacts of traffic. Cultural Heritage and Archaeology A desk study relating to archaeological and cultural resources has been undertaken, in addition to a site walkover survey. Despite the rich history and abundance of historical sites Non-Technical Summary Final 14

19 in the Ouarzazate province, no archaeological resources were identified in the Project site and study area, so no specific mitigation measures are considered necessary. A protocol for an archaeological watching brief has been detailed in case a chance find occurs, which will detail the required procedures to protect, report and preserve any archaeological finds. Landscape and Visual The landscape is an important asset for tourism in Ouarzazate. There are no anthropogenic elements on the study area other than the NOORo 1 CSP, access roads for the village of Tassellmant and the solar projects, and the two telecommunication antennas in the intersection of the N10 and Tasselmant road. The NOORo III project, due to the height of the tower, which will be 247m, will be clearly visible from all nearby sensitive receptors. This impact results from the choice of technology, that was informed by the analysis in the FESIA. Solar tower power plants are a cause of concern due to the Glare Effect. The aerial surveys undertaken in large tower facilities in the US showed that heliostats in standby mode can cause glare to aerial observers (pilots). The values were always below the ocular damage threshold. However, the glare from heliostats can cause after-image at far distances (up to 6 miles). Plant Operating System: Each heliostat will have its own independent PLC (Local Controller-LOC) to control and monitor the heliostat position. In addition there will be a redundant main control unit that will coordinate and control the performance of all the Plant heliostats. In case of Plant black-out, there will be several UPS systems that will guarantee the power supply to all solar field local controllers and main control unit so that correct operation of the solar field control system will be maintained. In the event of communication failure with main control unit, each LOC will have programmed a safety sequence that, after a certain time, will move the heliostat to a safe position (stow/horizontal position). Regarding the glare effect of mirrors in the road/ airport, each LOC will have programmed several security zones. The outside area of the Plant will be one of them. Tracking will not be permitted in this area. Therefore, if a LOC receives a tracking order in a fixed point outside the Plant, it will reject the command. In addition, in case one heliostat in its stopped position has the reflected vector pointing outside the Plant, it will generate an alarm and, in case of danger, the central control system will order the movement of the heliostat out of the zone. Mitigation measures to minimise the glare effect may include: Non-Technical Summary Final 15

20 A letter sent to the Civil Aviation Authority, to Ouarzazate Airport and to the airlines that fly to Ouarzazate notifying pilots of potential glare from the facility. The letter is intended to provide advanced notice to pilots flying over the area so that they are aware of the potential glare as they approach the site and will not be surprised by it. Modification of Heliostat Standby Positions to reduce the irradiance and number of heliostats that can reflect light to an aerial observer. Some strategies that can be considered include the following: o o o o Increase the number of aim points near the receiver and have adjacent heliostats point to different locations so that the number of glare-producing heliostats visible from the airspace above is minimized at all locations Position heliostats vertically or in other orientations that minimize glare Bring heliostats up to standby position at top of receiver sequentially as needed to avoid having a large number of heliostats reflecting light into the airspace above Incorporate a glare shield near the receiver that can serve as both the aim point for heliostats in standby mode and a preheater for the water entering the receiver Public Participation Several Community Consultation meetings have been held throughout the project scoping, planning and design phases. A further community consultation meeting was undertaken in February 2015 to inform the stakeholders of the details of NOORo III and incorporate their concerns in the assessment undertaken in the SESIA. Measures to compensate and/or mitigate the negative impacts that the community voiced in the consultation meeting have been incorporated in the design, operation and management of the proposed facility. The meeting was considered to fulfil its aims, for the following reasons: It allowed for precise information to be provided about water use. It confirmed that the concerns raised by the population (employment of local people, water use, employment) were in line with the mitigation measures being proposed (e.g. minimal water use, zero wastewater discharges, water treatment for reuse onsite, inclusion of provisions in the CESMP / ESMP to promote the employment of the local population and the provision of training). The detailed report of the community consultation meeting is provided in Appendix 1. Environmental and Social Management Plan Non-Technical Summary Final 16

21 The requirements for the Environmental and Social Management Plan for construction and operation are presented in Volume 3 of this SESIA. The ESMP serves as a basis for the preparation of comprehensive management plans in order to avoid, prevent, reduce or rectify environmental and social impacts that may arise during both construction and operation. For construction the ESMP is termed Construction Environmental and Social Management Plan (CESMP) and for Operation it is termed Operation Environmental and Social Management Plan (OESMP). Issues covered within each framework include: environmental and social management staff roles and responsibilities, environmental and social requirements and compliance, environmental training and social awareness programmes, and monitoring, recording, inspection and auditing protocol. The following recommendations are made to ensure management and monitoring of NOORo III tower CSP during construction and operational phases is in accordance with international best practices: 1. Prepare a detailed Construction Environmental and Social Management Plan and ensure that a full-time Environmental/Social Co-ordinator is appointed to manage and oversee day - day environmental/social management/monitoring activities, training and reporting. 2. Independent environmental audits should be undertaken quarterly to monitor compliance with MEMEE/WB/IFC standards and this information reported to the lenders and regulators. 3. Prior to operations commencing, an EMS consistent with ISO should be developed and implemented by the Operations & Maintenance Company. This should be subject to external auditing in the future. The EPC and Contractors will be responsible for the development of their own, activity specific CESMP. The Operator will be responsible for the of their own, activity specific OESMP MASEN and the IFI, will receive, review and comment on the routine monitoring reports supplied by the EPC, and Operator. Environmental impacts and mitigation measures summary table The following table provide a summary of the identified environmental impacts, their significance, the main mitigation measures proposed, the responsibilities for the implementation of the mitigation measures and the main monitoring activities. This table only outlines what are considered to be the main mitigation measures and monitoring activities. A Non-Technical Summary Final 17

22 full description of the main mitigation measures and monitoring requirements for the NOORo III tower CSP Plant is provided below. Non-Technical Summary Final 18

23 Environmental Issue Soil Significance Mitigation Measure Responsibility Residual Monitoring Spillages Material storage Cross contamination Water and Wastewater Moderate to Minor Moderate to Minor Minor to Negligible Preparation of the CESMP and OESMP. Appropriate material and waste storage design and handling procedures. Soil and groundwater protection measures (i.e. bunds). Establish a spill response contingency plan Provide staff training Leak detection systems (operator only) Contractor and Operator Minor Negative Conduct remediation monitoring following a spill incident. Twice yearly groundwater monitoring at two wells of Tasselmant applicable for all three phases of NOORo SCP(operator only) Construction a. Water use b. Wastewater a. Minor b. Moderate Preparation of the CESMP Oily wastewater from vehicle maintenance will be collected via interceptors. Construction of a specific area for basic site machinery maintenance work. Construction of a settling basin The storage of waste generated on site shall be located outside areas in which runoff could affect nearby watercourses Employee training to minimise water consumption and ensure an understanding of wastewater issues Contractor a. Negligible b. Minor Site inspections will be carried out regularly to ensure that all wastewater generated is properly managed, and no leakages or spill overs occur. The basins must be monitored to establish the regularity of sludge drainage. NOORo III TSP Non-Technical Summary Final 19

24 Environmental Issue Significance Mitigation Measure Dismantling of storage tanks shall include the final drainage of any existing water and sludge, removal of the waterproofing sheet, and filling in of the basin to its initial configuration. Demolition of ditches. All excess products must be taken to the landfill site. Responsibility Residual Monitoring Operation a. Water use b. Wastewater Air quality Dust a. Minor b. Moderate Minor to Moderate Preparation of a waste management plan within the OESMP Recycle and re-use of the treated effluent to minimise primary water resource use All above ground tanks and basins will have overflow pipes to an effluent collection point. Employee training to minimise water consumption and wastewater issues. Preparation of the CESMP and OESMP Dust control measures should be implemented for transport activities and groundworks. All machinery should be inspected for good operation stockpiles should be covered Burning of waste is forbidden Hazardous materials stored on site with potential gas emissions will be located in well ventilated secure areas Operator Contractor and Operator a. Negligible b. Minor Construction: Minor Negative Operation: Negligible Routine testing of the effluents to verify compliance with technical specifications, national legislation. Routine inspection of drainage wells located under the evaporation ponds. Periodic ambient air quality monitoring (NOx & SOx) will be undertaken at the identified sensitive receptors, in order verify that national ambient air quality MALs are not exceeded. Routine monitoring of the dust levels and wind conditions NOORo III TSP Non-Technical Summary Final 20